The responsible party for data protection as it applies to this website is Clover Portugal Lda, Ruas 3 & 5 - Lt. 17/18B, Zona Industrial da Varziela, 4480-091 Árvore, Vila do Conde, Portugal.

If you have any questions relating to the German Federal Data Protection Act or the GDPR, please contact the external data protection officer appointed by Clover Germany GmbH

Kurt Ebert (Ebert & Partner Consulting GbR)
Graf-Eberhard Str.1
71229 Leonberg, Germany
Email: kurt.ebert@ebert-partner.de                                                                                     
 
This web portal is operated by Clover Portugal LDA but data collected via this website may also be shared with other European companies within the Clover Imaging Group (hereinafter referred to as "CIG EMEA") subject to the provisions of the EU General Data Protection Regulation (GDPR). Please read section (8.3) Processing of data in group companies. In the text that follows, "we", "us" and "our" refer to the companies of the CIG EMEA group of companies.

It is very important to us to handle your data correctly in respect of your personal rights and the observance of your right to informational self-determination with regard to the use of your personal data. Your personal data will be processed in accordance with the relevant legal provisions, in particular the GDPR and national data protection legislation.

The latest version of our privacy policy is dated 28/05/2019. We reserve the right to amend the privacy policy at any time to take account of changed legal requirements and regulations. Please keep yourself up-to-date with any changes to the privacy policy by following the relevant link on our website.

Please read the privacy policy carefully. If you are not in agreement with this policy, you should refrain from using our website and should not share any personal data with us.

Our privacy policy uses terms and definitions as set out in the GDPR, in particular those found in Article 4 GDPR. For the purposes of this policy, we are the "controller" and you are the "data subject". Data that relates either directly or indirectly to you is considered "personal data". In this privacy policy, any reference to your "data" generally means data that relates either directly or indirectly to you as a natural person. This includes, for example, your name, address, telephone number, email address, company name and other information that you submit via forms on our website.

You can, of course, also visit our website without disclosing any personal information. Whenever you use our website, data is automatically collected and processed but such data cannot be linked to you. Refer to the following sections of this privacy policy for further details:

  • "Web service log files",
  • "How we use cookies",
  • "Google Analytics web analytics tool".

(1) Automatic collection, processing and use of personal data relating to non-registered and registered users

(1.1) Web service log files and server data

When you access the pages of our website via your browser, the server automatically saves the data (in the form of log files) that is necessary to operate a web service: the name of your browser, the name of your Internet service provider, the IP address of your PC, the address of the page from which you have accessed our website, the name of your operating system, which of our web pages you browse and the date and duration of your visit. This data is stored temporarily in the log files and then automatically deleted. The data is stored to enable analysis of the activities that led to an error if there are any problems, and to make it possible to identify, clarify and defend against online attacks (e.g. Distributed Denial of Service (DDoS) attacks, hacker attacks, identity fraud).

(1.2) Cookies

Our website uses cookies. Cookies are small files that the web server transfers to your PC. These files are used to track how you navigate the pages of our website or to accept orders.

One way to distinguish between the different types of cookie is by the length of time for which they are stored. Session cookies are automatically deleted when you close your browser. A session cookie can be used to manage an order form or retain the details of services that are of particular interest. Permanent cookies, on the other hand, remain stored on your PC; you can find details of the storage durations via your browser. A permanent cookie can be read again the next time you visit our website. You can delete the permanent cookie after visiting our website to prevent this from happening.

Another way to distinguish between the different types of cookie is by their origin. First-party cookies always come from the website that is specified in the address bar of your browser. Third-party cookies come from websites that you may not have visited directly but that are incorporated into the pages provided by the first party in the form of images or advertisements. You can find information about the origin of the cookies stored on your PC via your browser.

(1.2.1) How we use cookies

The EU Cookie Directive states that consent is required to place permanent cookies for purposes other than ensuring proper communication with the web server. If you do not exercise your right to decline cookies, we will consider your continued use of our website to be consent to our use of cookies as described here.

To the extent that your browser permits, our web server will place the following permanent cookies:

_ga: This is a permanent cookie with a validity of two years. It is used for Google Analytics purposes; see section (1.3) of this policy.

_gat: This is a permanent cookie with a validity of two minutes. It is used for Google Analytics purposes; see section (1.3) of this policy.

Right to decline

Most browsers are configured to accept cookies. Please change the relevant settings in your browser if you wish to disable this feature. If your browser does not accept cookies, you may not be able to enjoy the full functionality of all the pages of our website.

(1.2.2) How can I disable cookies?

You can adjust your browser settings to decline all cookies, decline only third-party cookies, or allow only temporary cookies. Please refer to the help pages of your browser to find out which settings you need to make.

(1.3) Google Analytics/Google Maps web analytics tools

We use Google Analytics on our website. It is a web analytics service provided by Google LLC, Gordon House, Barrow Street, Dublin 4, Republic of Ireland, hereinafter referred to simply as "Google".

Certified in accordance with the EU-US Privacy Shield Framework https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active,

Google guarantees that EU data protection guidelines are also observed when data is processed in the USA.

The Google Analytics service is used to analyse user behaviour on our website. The legal basis is Article 6, point 1(f) GDPR. Our legitimate interest is in the analysis, optimisation and economic operation of our website. Usage and user-related information, e.g. IP address, location, time, or frequency of visits to our website, will be transferred to a Google server in the USA and stored there. We also use the Google Analytics anonymization function. This feature allows Google to shorten the IP address within the EU or EEA.

The data collected will then be used by Google to provide us with an analysis of visits to and use of our website. The data may also be used to provide other services associated with the use of our website and use of the Internet.

Google undertakes not to link your IP address with other data. In addition, at https://policies.google.com/technologies/partner-sites?hl=en,

Google provides additional information about data protection requirements and about the options for prohibiting the use of data.

Google also provides an opt-out add-on, plus additional information, at https://tools.google.com/dlpage/gaoptout?hl=en.

This add-on can be installed using common Internet browsers and gives you additional control over the data that Google collects when you access our website. The add-on tells the Google Analytics JavaScript (ga.js) that information relating to your visit to our website should not be shared with Google Analytics. The add-on does not prevent information from being shared with us or with other web analytics services. As you would expect, this privacy policy also provides details of any additional web analytics services we might use.

We also use Google Maps on our website, to indicate our location and to generate route information. This service is provided by Google LLC, Gordon House, Barrow Street, Dublin 4, Republic of Ireland, hereinafter referred to simply as "Google".

Certified in accordance with the EU-US Privacy Shield Framework

https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active,

Google guarantees that EU data protection guidelines are also observed when data is processed in the USA. To enable certain fonts to be displayed on our website, a connection is established with the Google server in the USA when you visit our website. If you access Google Maps via our website from the embedded application, Google will place a cookie on your device via your Internet browser. Your user settings and user data will be processed in order to show our location and generate route information. In this instance it is possible that Google will use servers in the USA. The legal basis is Article 6, point 1(f) GDPR. Our legitimate interest is in optimising the functionality of our website. Establishing a connection with Google in this way means that Google can determine the website from which your enquiry has been sent and the IP address to which it should send route information. If you do not agree to your data being processed in this way, you can prevent cookies from being placed by selecting the appropriate settings in your Internet browser. See the "Cookies" section above for further details.

In addition, the use of Google Maps and any information acquired via Google Maps is subject to the Google Terms of Service https://policies.google.com/terms?gl=DE&hl=de and the Google Maps Terms of Service https://www.google.com/intl/en_en/help/terms_maps/.

Google provides further information on this topic at:

https://adssettings.google.com/authenticated

https://policies.google.com/privacy

Right to decline

You can also prevent the collection of data generated by the cookie and relating to your use of the website (incl. your IP address) by Google and the processing of such data by Google. You can do this by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

More information about terms of use and privacy at Google can be found at https://www.google.com/analytics/terms/gb.html or at https://policies.google.com/?hl=en&gl=de.

(2) Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks as well as the organisation of our business, financial accounting and compliance with legal obligations, such as archiving. The data we process in these instances is the same data that we process in connection with the provision of our contractual services. The bases for this processing are Article 6, point 1(c) GDPR and Article 6, point 1(f) GDPR.   Customers, prospective customers, business partners and visitors to the website are subject to the processing of data as outlined above. The purpose of and our interest in the processing of data is in the administration, financial accounting, office organisation and the archiving of data, i.e. tasks relating to business continuity, performance of our duties and provision of our services. Deletion of data relating to the provision of contractually required services and communication will take place in line with the specifications for such processing activities. We may disclose data to or share data with financial authorities and consultants, e.g. tax advisors or auditors, as well as other billing offices and payment service providers. Furthermore, on the basis of our operational interests, we may store information about suppliers, operators and other business partners, e.g. to facilitate contact at a later date. The data is primarily business-related and we generally store it permanently.

(3) How we process your personal data as a customer or supplier

On our portal, we collect data (contact form, newsletter requests, dealer registrations, webshop registrations) from natural persons who contact us or who are employed by or represent a company with which we have a business relationship. This includes your name, the name of your company, the address of your company, business contact details such as your email address and telephone number, and details of your position in the company. Your data will be processed on the basis of our legitimate interest in contacting you as a representative of our customer, as well as the legitimate interests of the company that you represent in establishing communication. Your contrary interests may outweigh our interests, e.g. if you leave your company.

It goes without saying that you, as the data subject, have certain rights in relation to data protection, such as the right to withdraw consent, the right of access to details of the data stored in relation to your person, and other rights. Please read section (8.5) Your rights in relation to the processed data.

For contractual purposes, we process data relating to your company in our CRM and in the planning, manufacturing, logistics and financial modules of our ERP. Depending on your role and responsibility within your company, this may include the data mentioned above that relates directly to your person. However, the purpose of processing this data does not relate to you as an individual but rather to your company as our business partner.    Data protection legislation does not apply to data that relates purely to a business and not to a natural person.

(3.1) Registration as a dealer

You can register as a dealer by submitting a form on our website. Your data, together with any message you submit, will be sent to the central customer service team as an email. This team will direct your registration to the relevant field service, a representative of which will then contact you. The legal basis for this processing is your contractual relationship with us.

Your data will then be stored in our CRM and will be used by us and by other CIG EMEA companies on the legal basis of your contractual relationship with us for the purposes of customer care, and responding to your enquiries and orders. Your data will also be used for promotional purposes on the legal basis of our legitimate interest in furthering our customer relationship. Please also read section (8.3) Processing of data in group companies.

We will also use your data to provide you with information and details of special offers by post or by electronic newsletter. We will obtain your express consent to send such communications before doing so where this is required by law. You may object to such usage at any time, e.g. using the contact form on our website.

(3.2) Registration for our webshop and processing in the webshop

You must complete a corresponding form on our website in order to use the CIG EMEA webshop. Your data, together with any message you submit, will be sent to the central customer service team as an email. This team will arrange for you to have access to the webshop.

In the webshop, your data will be processed for the purposes of handling your orders; the legal basis for such processing is your contractual relationship with us.

We will also use your data to provide you with information and details of special offers by post or by electronic newsletter. We will obtain your express consent to send such communications before doing so where this is required by law. You may object to such usage at any time, e.g. using the contact form on our website.

We process our customers' data as part of ordering processes in our online shop, in order to make it possible to select and order the required products and services and in order to facilitate payment and delivery or performance.

The data processed includes: inventory data, communication data, contract data and payment data; the data subjects include: our customers, prospective customers and other business partners. Data is processed for the purpose of providing contractual services within the framework of the operation of an online shop, and for the purposes of billing, delivery and customer services. We place session cookies to make it possible to save the content of your shopping basket and permanent cookies to store your login status.

We process the data in order to fulfil our contractual services and in order to implement contractual requirements (e.g. manage orders) and insofar as such processing is required by law (e.g. statutory archiving of business transactions for commercial and tax purposes). The data that is designated as required is necessary for the substantiation and fulfilment of the contract. We will disclose said data to third parties only in connection with delivery and payment or in connection with statutory permits and obligations, and when such disclosure is based on our legitimate interests, of which we inform you in this privacy policy (e.g. to legal and tax advisors, financial institutions, shipping companies and authorities).

Users also have the option of creating a user account, used primarily for viewing details of their orders. Users will be informed of the relevant mandatory information during the registration process. User accounts are not public and cannot be indexed by search engines. When a user cancels an account, the user data that is linked to the user account will be deleted, unless the information must be retained on the basis of commercial or tax requirements. Information in the customer account will be stored until such time as it is deleted, and will subsequently be archived if there is a legal obligation to do so or if we have a legitimate interest in doing so (e.g. in the case of legal disputes). Following cancellation, users are responsible for backing up their data prior to the end of the contract.

As part of the registration and subsequent log-on-processes and during use of our online services, we will save the IP address and log time of each user action. The data will be stored on the basis of our legitimate interests and those of the users in relation to protecting against fraudulent use and other unauthorised use. This data will, in principle, not be shared with third parties unless such action is necessary in order to pursue our statutory rights as a legitimately interested party or unless there is a legal requirement to do so.

The data will be deleted upon the expiry of statutory rights and obligations and other contractual rights or obligations (e.g. payment claims or performance obligations arising from contracts with customers), and the requirement to retain the data will be reviewed every three years; in the case of retention owing to statutory archiving obligations, the data will be deleted once such obligations no longer apply.

(4) Operational analysis and market research

In order to operate our business cost-effectively and identify market trends as well as the needs of our contractual partners and users, we analyse the data that is available to us in relation to business transactions, contracts, requests etc. As part of this analysis, we process inventory data, communication data, contract data, payment data, usage data and meta data on the basis of Article 6, point 1(f) GDPR. Data subjects include contractual partners, prospective customers, customers and visitors to and users of our online services. The analyses will be carried out for the purpose of operational assessment, marketing and market research. As part of this process we may analyse the profiles of registered users, including details of the services they have used. The analyses help us to improve user friendliness, optimise our services and increase operational efficiency. The analyses are used purely by us and are not made available to external parties, unless the analyses in question are anonymous and based on aggregated values. If the analyses or profiles are linked to personal data, the details will be deleted or anonymised when the user cancels their account, or two years from the date of conclusion of the contract. Furthermore, overall operational analysis and general trend analysis are performed anonymously where possible.

(5) Newsletter

As a rule, you will normally receive an electronic newsletter because you have specifically asked to receive it. When you submit a request to receive our newsletter, we also save details of your consent to receive the newsletter, along with the date.

If we are not certain of the identity of the requestor, before sending out the newsletter we apply the double opt-in procedure, i.e. we will only send you a newsletter via email if you have expressly confirmed to us beforehand that you have subscribed to the newsletter. To this end, we will send you a notification email and ask you to click a link contained in the email to confirm that you wish to receive our newsletter.

Right to decline

You may withdraw your consent at any time. The easiest way to do this is to click the corresponding link in our newsletter. You can also use the contract form to inform us of your objection.

(6) Data protection information relating to the application process

As part of the application process, applicants are required to provide us with the necessary data for assessment and selection purposes. The job description provides details of what information is required; where application is made via an online form, details will be provided along with the form. In principle, the information we require is information that relates to the individual, such as name, address, contact details and proof that the individual has the necessary qualifications for the job in question. We will also be happy to provide confirmation of what information is required on request. Where such a functionality is supported, applicants can submit their applications via an online form. The data is encrypted using the latest technology before being sent to us. Applicants can also submit their applications via email. However, please note that emails sent via the Internet are not generally encrypted. As a rule, emails are encrypted while in transit but not on the servers that send or receive them. As such, we can accept no responsibility for the application while it is in transit from the sender and before it is received on our server. Applicants are welcome to contact us to discuss how to submit their application, or can send us their application by post. In the event of a successful application, the data provided by applicants may be subject to further processing by us in connection with the employment relationship. If the application does not result in the applicant being offered a position, the applicant's data will be deleted. Applicant data is also deleted when applicants withdrawn their application, which they are entitled to do at any time. Unless an applicant has rightfully withdrawn an application, application data will be deleted following a period of no longer than six months; this period gives us time to ask the applicant any follow-up questions regarding their application and to fulfil our statutory obligations to provide proof that applicants have received equal treatment. Invoices for any reimbursement of travel expenses will be archived in accordance with taxation regulations. Applicant data will be processed on the basis of Article 6, point 1(b) GDPR (application process as a contractual or pre-contractual relationship). Insofar as the application process requires applicants to provide special categories of personal data as defined by Article 9, point 1 GDPR (e.g. health data such as disability or ethnic origin) so that the controller or the data subject can exercise the rights ascribed to them under employment legislation and social security/protection legislation and so that they can comply with any corresponding obligations, such data will be processed pursuant to Article 9, point 2(b) GDPR or, in the case of the protection of the vital interests of the applicant or other persons, pursuant to Article 9, point 2(c)   GDPR or, for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, for the provision of health or social care or treatment or for the management of health or social care systems and services, pursuant to Article 9, point 2(h) GDPR. If the data subject has voluntarily given consent for the processing of specific categories of data, the data will be processed pursuant to Article 9, point 2(a) GDPR.

If applicant data is processed in Germany, Sections 22 and 26 of the German Federal Data Protection Act also apply.

(7) Contact form

When you enter your data in a contact form, this data, together with any message you submit, will be sent as an email to the central customer service team and to the marketing department. These teams will direct the message to the relevant person. Your data will be processed only for the purpose of responding to your enquiry; the legal basis for the processing is a contractual relationship with you. Data from contact forms is not stored permanently.

(8) Further explanations regarding data protection

(8.1) Responsible party for data protection

The company referred to at the beginning of this privacy policy is the data controller under data protection legislation only for the web pages published under the cloverimaging.eu domain. Said company is not responsible for pages from partner companies which can be accessed from pages on our website.

(8.2) Linked pages and other websites

The respective partner companies are responsible for data protection on linked pages. If you access pages from partner companies or other third parties via linked pages, please refer to the legal notice or the privacy policy of the linked website for details about data protection.

(8.3) Processing of data in group companies

Customers and business partners may perceive CIG EMEA to be a single company. In fact, the group comprises several companies that have undertaken to collect, process and use your data pursuant to the same European data protection legislation.  Depending on the location or the country from which you wish to enter into a business relationship with CIG EMEA or have already entered into a business relationship with CIG EMEA, your data may be processed and used by the companies listed below for the various specified purposes:

CLOVER IMAGING GROUP EMEA

Clover Portugal, Lda
Ruas 3 & 5 - Lt. 17/18B
Zona Industrial da Varziela
4480-091 Árvore
Vila do Conde
Portugal

Central data processing for CIG EMEA;
Operation of the websites;
Customer service;
Order processing

Clover Germany GmbH
In den Wolfsmatten Geb. 142
77955 Ettenheim
Germany

Customer service;
Order processing

Clover Environmental Solutions GmbH
In den Wolfsmatten Geb. 142
77955 Ettenheim
Germany

Customer service;
Order processing

Clover Serbia d.o.o.
Rade Koncara 1
21131 Petrovaradin
Serbia

Central data processing for CIG EMEA;
Central customer service;
Order processing;
Webshop

Clover Dataproducts of Ireland Ltd
39/40 Upper Mount St.
Dublin 2.
Republic of Ireland

Customer service;
Order processing

Clover Environmental Solutions Ltd
Unit 8 & 9 First Quarter
Blenheim Road
Epsom
Surrey KT19 9QN
United Kingdom

Customer service;
Order processing

 

Under the terms of data protection legislation, each CIG EMEA company can be the controller for your personal data ("jointly responsible for processing" or "joint controllership"). Data protection agreements ensure that data protection and data security are guaranteed for your data at the level required by European legislation, even if your data is processed and used outside the European Economic Area.

Joint controllership as referred to above is relevant for data in the CIG EMEA Group shared CRM as well as for the processing of data in the webshop.

For order management purposes, each company is the sole controller in relation to the processing of the data that is required to allow the company to fulfil its contracts with customers and suppliers; this applies also to the processing of financial data.

As described in section (8.5), you are entitled to assert your rights as a data subject under protection legislation against every controller. The central customer service team will direct your enquiry to the company within the CIG EMEA group that is responsible for the business relationship with you.

(8.4) Disclosure of your personal data to bodies outside the CIG EMEA group of companies

We will not disclose your data to any third parties outside the CIG EMEA group without your consent unless such disclosure is required or permitted for valid legal reasons or the request for disclosure is based on a judicial or official requirement. We would, however, disclose your personal data to a third party or transfer it to a third party in connection with the sale of our company or parts thereof. Your data would be used by any such third party for the purpose of continuing the business relationship with you.

(8.5) Your rights in relation to the processed data

You have rights as a data subject and you are entitled to assert those rights against every company within the CIG EMEA group.

You have a right of access in relation to the data being processed that relates to you (Article 15 GDPR). You can rectify your data pursuant to Article 16 GDPR or, if certain requirements as outlined in Article 17 GDPR apply, have it erased. Pursuant to Article 18 GDPR, you have a right to restriction of processing; if you assert a particular personal situation, you also have the right, pursuant to Article 21 GDPR, to object to the processing of your data in general terms or to the processing of your data in specific areas. You have the right to request that data you have made available to a CIG EMEA group company be published in a commonly used electronic form. You have the right to withdraw your earlier consent for processing of your data at any time with effect for the future. This means that the withdrawal of consent will apply only to future processing of your data; data that has already been processed will thus remain compliant with data protection legislation.

You have the right to object to the use of your contact and address data by CIG EMEA group companies to send you promotional material and information if you have not expressly requested such contact.
To assert your rights, please use our contact form or email us at cc@clovertech.eu.

You have the right to escalate any complaints about the way in which we process your data to a data protection supervisory authority.

If you decide to have your data deleted, please be aware that we will not be able to provide you with the services, or some of the services, available via our website and that you will no longer be able to use the full functionality of our website.

For more information about your rights, please refer to our customer protection information

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